Justia Idaho Supreme Court Opinion Summaries

A developer began constructing and selling duplex-style condominiums in Bonner County, Idaho, using a standard real estate purchase and sale agreement (PSA) form. The buyers, including a real estate agent and his wife, entered into PSAs for two units, planning to use them as personal and investment properties. The PSAs referenced detailed “Plans and Specifications” for the construction and finishes of the units, but no such documents were attached or ever created. Disputes later arose over the scope and quality of the promised finishes, especially after the developer communicated price increases and clarified the options for base and upgraded finishes. The buyers sued to enforce the contracts and sought specific performance, while the developer counterclaimed for a declaration that the PSAs were invalid due to indefiniteness.The District Court of the First Judicial District, Bonner County, conducted a bench trial. It found that the PSAs for the disputed units were missing essential material terms, specifically the absent Plans and Specifications, which left the scope of work, finishes, and price adjustments undefined. The court concluded that no enforceable contract was formed and denied the buyers’ request for specific performance. The developer was ordered to return deposits but was deemed the prevailing party, entitling him to attorney fees and costs. The district court also conditioned a stay of its judgment pending appeal on the posting of an additional bond.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s judgment. It held that the PSAs were invalid and unenforceable because they omitted material terms necessary to define the contractual obligations. The buyers’ challenge to the additional bond was deemed moot given the disposition of the contract claims. The award of attorney fees to the developer was upheld, and the Supreme Court granted him attorney fees and costs for the appeal as the prevailing party. View "SCHUSTER v. MILBRATH" on Justia Law

This case stems from a fatal plane crash in which a pilot, Chelsea Brittney Infanger, collided with exhaust stacks owned by a processing plant near the Burley Municipal Airport in Idaho. The stacks, which extended over 100 feet high, were situated within the runway’s approach path and had been the subject of prior regulatory concern. The pilot’s parents brought a wrongful death suit, alleging that the Idaho Department of Transportation’s Division of Aeronautics negligently failed to regulate or mitigate the known risk posed by these stacks, arguing that various statutory, common law, special relationship, and contractual duties compelled the Division to act.After settlements with other defendants, the case proceeded against the Division in the District Court of the Fourth Judicial District, Ada County. The Division moved for summary judgment, contending it owed no individualized duty to the deceased under the Airport Zoning Act, common law, or through a special relationship, and that it was immune under the Idaho Tort Claims Act. The district court agreed, holding that the Division’s statutory duties were general obligations to the public, not specific duties to individual aviators, and found no basis for liability under special relationship or contract theories. The court granted summary judgment to the Division, and the plaintiffs appealed.The Supreme Court of the State of Idaho affirmed the district court’s decision. It held that the Airport Zoning Act did not create a tort duty to a particular class of persons, but rather imposed general obligations for public safety, and thus could not support a negligence per se claim. The Court also found that the plaintiffs did not preserve or demonstrate the elements necessary for a special relationship or assumed duty sufficient to impose liability. The Court declined to award attorney fees, but granted costs to the Division. View "Infanger v. State of Idaho, Idaho Department of Transportation" on Justia Law

A local man participated in a drag show at a public event in Coeur d’Alene City Park, performing on stage before an audience that included children. A member of the audience recorded the performance and sent the video to a local blogger, who did not attend the event. After reviewing the video, the blogger posted content on social media accusing the performer of exposing his genitalia to minors during the show. The blogger edited and posted a version of the video with a blurred area, claiming it covered fully exposed genitals, and invited public scrutiny and police investigation. These statements led to public backlash, an official investigation (which was closed for lack of evidence), harassment of the performer, job loss, and significant mental distress.The performer sued the blogger for defamation and defamation by implication in the District Court of the First Judicial District, Kootenai County. Both parties filed motions for summary judgment, which were denied. The court ruled that the performer was not a public figure or limited-purpose public figure, allowing him to seek punitive damages. At trial, the jury found in favor of the performer, awarding substantial compensatory and punitive damages, and found that the blogger acted with actual malice. The district court entered judgment accordingly. The blogger appealed, raising ten alleged errors related to jury instructions, verdict forms, damages, and legal standards.The Supreme Court of the State of Idaho reviewed the appeal. It declined to address most issues due to pervasive deficiencies in the appellant’s briefing, including lack of cogent argument, fabricated authority, and unpreserved issues. The Court held that even if the district court erred in determining the performer was not a limited-purpose public figure, the error was harmless because the jury found actual malice. The Court affirmed the district court’s judgment and awarded costs to the respondent. View "Posey v. Bushnell" on Justia Law

A man was stopped by law enforcement while riding as a passenger in a car due to a traffic infraction. During the stop, officers identified him and found that he was on felony probation. The officers searched a backpack at his feet, which contained a significant quantity and variety of illegal narcotics, as well as items suggestive of drug distribution. The man denied ownership of the backpack, claiming it belonged to his girlfriend. Subsequent investigation revealed that he was subject to a probation agreement that included both waiver of his Fourth Amendment rights and consent to searches by law enforcement.He was charged in two separate cases with various drug-related offenses, including possession with intent to deliver and possession of drug paraphernalia. The cases were consolidated in the District Court of the Fourth Judicial District, Ada County. He moved to suppress the evidence found in the backpack, arguing that the search was unconstitutional. The district court denied his motion, finding that he lacked standing to challenge the search due to the express waiver of his Fourth Amendment rights in his probation agreement.After trial, a jury found him guilty on multiple counts, and he was sentenced to a unified fifteen-year term, with five years fixed. On appeal to the Supreme Court of the State of Idaho, he argued that the district court erred in treating his waiver as a categorical bar to standing, particularly since officers did not know of the waiver at the time of the search.The Supreme Court of the State of Idaho affirmed the district court’s denial of the motion to suppress. The Court held that an express waiver of Fourth Amendment rights in a probation agreement extinguishes any legitimate expectation of privacy and therefore precludes standing to challenge the search, overruling its prior decision in State v. Maxim, 165 Idaho 901, 454 P.3d 543 (2019), to the extent it held otherwise. View "State v. Al-Mafrachi" on Justia Law

A plaintiff, seeking to secure retirement funds, sold an apartment complex in 2017 and was introduced to Ronald Hill, who represented himself as a financial advisor but was only licensed as an insurance producer. Hill persuaded the plaintiff to invest the sale proceeds in a product offered by Future Income Payments, LLC (FIP), and also to purchase an Indexed Universal Life (IUL) insurance policy, initially from Minnesota Life and later from Pacific Life. Hill proposed that the proceeds from the FIP investment would fund the premiums for the Pacific Life IUL policy. FIP was subsequently exposed as a Ponzi scheme, resulting in the plaintiff’s loss of the investment and inability to pay the insurance premiums.The plaintiff and other parties filed suit in the District Court of the Third Judicial District, Canyon County, Idaho, asserting claims including negligence against Hill and Pacific Life. By trial, only Hill and Pacific Life remained as defendants, with the plaintiff as the sole remaining claimant. The trial proceeded on a common law negligence claim. The jury found both Hill and Pacific Life negligent, determined Hill was acting as Pacific Life’s agent, and apportioned 60% of fault to Pacific Life and 40% to Hill. The district court entered judgments against Pacific Life, including joint and several liability with Hill for a portion of damages. Pacific Life appealed, challenging the district court’s denial of motions for directed verdict.The Supreme Court of the State of Idaho reviewed the appeal and held that, under Idaho law, Pacific Life owed no duty to protect the plaintiff from pure economic loss absent an applicable exception to the economic loss rule. The Court further found insufficient evidence to establish Hill acted as Pacific Life’s agent when marketing the FIP investment. The Court vacated the judgments against Pacific Life and remanded with instructions to enter judgment in favor of Pacific Life. View "Shelstad v. Pacific Life Insurance" on Justia Law

The petitioner was convicted by a jury in 2018 of one count of felony lewd conduct with a minor under sixteen and two counts of felony sexual abuse of a child under sixteen, with a sentencing enhancement as a repeat sexual offender. He received a life sentence with a twenty-year fixed term for lewd conduct and two concurrent twenty-five-year sentences for sexual abuse. Following his conviction, he filed a pro se petition for post-conviction relief, later supported by an amended affidavit. Central to his petition was the claim that his trial counsel failed to communicate his acceptance of a favorable plea offer from the State, resulting in the offer being withdrawn.The State responded with a motion for summary disposition, supported by an affidavit from the petitioner’s trial counsel, who stated that the petitioner had rejected the plea offer and instead proposed a counteroffer, which the State rejected. The district court granted the State’s motion, concluding that the petitioner had provided only conclusory allegations unsupported by admissible evidence. On appeal, the Idaho Court of Appeals affirmed the district court, partly on the rationale that statements by post-conviction counsel at a hearing amounted to a concession regarding the lack of merit in the claim. The petitioner then sought review by the Supreme Court of the State of Idaho.The Supreme Court of the State of Idaho held that the petitioner’s post-conviction counsel’s statements did not constitute a binding concession and that the petitioner’s affidavit contained sufficient admissible, non-conclusory factual assertions to raise a genuine issue of material fact regarding his ineffective assistance of counsel claim. The Court determined that summary disposition was improper in light of conflicting affidavits about whether the petitioner accepted the plea offer. The judgment of the district court was vacated, the order summarily dismissing the petition was reversed, and the case was remanded for further proceedings. View "Ennis v. State of Idaho" on Justia Law

The petitioner was convicted by a jury of felony lewd conduct with a minor and two counts of felony sexual abuse of a child, resulting in substantial concurrent prison sentences. He later submitted a petition for post-conviction relief, alleging that his trial counsel failed to communicate his acceptance of a plea offer from the State, which would have resulted in a considerably lighter sentence. The petitioner claimed in an affidavit that he instructed his trial counsel to accept the State’s offer, but the offer was withdrawn after counsel failed to convey his acceptance.The District Court of the First Judicial District, Bonner County, granted the State’s motion for summary disposition and dismissed the petition, concluding that the petitioner’s affidavit was conclusory and lacked admissible evidence. On appeal, the Idaho Court of Appeals affirmed the district court’s judgment, relying in part on statements made by the petitioner’s post-conviction counsel at the summary disposition hearing, which were interpreted as a concession that the claim lacked merit. The petitioner then filed a petition for review with the Supreme Court of Idaho.The Supreme Court of Idaho reviewed the district court’s decision directly and held that the petitioner’s post-conviction counsel’s statements did not constitute a binding concession, and that the petitioner had presented sufficient admissible, non-conclusory evidence in his affidavit to create a genuine issue of material fact. The Court explained that the petitioner’s factual assertions regarding the plea offer and his instructions to counsel were within his personal knowledge and were not conclusory. Accordingly, the Supreme Court vacated the district court’s judgment, reversed the order summarily dismissing the petition for post-conviction relief, and remanded the case for further proceedings. View "Ennis v. State of Idaho" on Justia Law

A parole commission issued an arrest warrant for an individual who had absconded. The warrant authorized various law enforcement officers to detain the individual. A Nampa City police officer located the individual in Caldwell, Idaho, and arrested him, despite being outside his jurisdiction and without satisfying any of the statutory exceptions for extraterritorial arrests. After the arrest, officers searched the individual’s vehicle and discovered narcotics and a stolen firearm, leading to charges including unlawful possession of a firearm and possession of drug paraphernalia.The matter was reviewed by the District Court of the Third Judicial District, Canyon County. The defendant moved to suppress evidence, arguing that his arrest was unconstitutional under both federal and Idaho constitutional provisions due to the officer’s violation of Idaho Code section 67-2337(2). The district court denied the motion, concluding that the officer’s violation of the statute did not amount to a constitutional violation. The defendant entered a conditional guilty plea, reserving his right to appeal. The Idaho Court of Appeals affirmed the district court’s decision.The Supreme Court of the State of Idaho granted review. The Court applied a bifurcated standard of review, examining factual findings for clear error and freely reviewing constitutional questions. The Court held that a violation of Idaho Code section 67-2337(2) by a peace officer does not constitute a constitutional violation requiring suppression of evidence, absent a showing that the Idaho Constitution, state precedent, or unique state interests demand a different analysis from federal law. The Court affirmed the district court’s denial of the suppression motion and the judgment of conviction. View "State v. Satterfield" on Justia Law

Snap, a Delaware corporation, sued Vertical Raise, an Idaho LLC, and an individual, alleging tortious interference, misappropriation of trade secrets, and unfair competition. Liability was resolved in Snap’s favor on summary judgment. At trial, the jury awarded Snap $750,000 in unjust enrichment damages and $250,000 in punitive damages. However, the district court mistakenly entered judgment for $800,000, not $1,000,000. Snap sought an additur or new trial and discretionary costs. The district court granted both: costs were awarded, and the damages were increased via additur, but without giving Vertical Raise the option to accept or reject it.Vertical Raise appealed to the Supreme Court of Idaho, which in the prior case, Snap! Mobile, Inc. v. Vertical Raise, LLC, 173 Idaho 499, 544 P.3d 714 (2024), affirmed the costs award, reversed the grant of additur or new trial, and remanded with instructions to reinstate the jury verdict and enter an amended judgment accordingly. After remand, Vertical Raise’s surety bond paid the judgment and costs, but not post-judgment interest. Disputes arose over whether interest accrued from the dates of the original and amended judgments, or only from the post-remand judgment.In the present appeal, the Supreme Court of Idaho reviewed whether the district court erred by awarding post-judgment interest starting from the entry dates of the original and amended judgments. The Court held that post-judgment interest accrues from the dates when the original and amended judgments were entered, not from the date of the post-remand judgment, even if later judgments modify the amount owed. The Third Amended Judgment was affirmed. The Court also awarded Snap its attorney fees under Idaho Code section 12-121, finding Vertical Raise’s appeal unreasonable and without foundation. Costs on appeal were awarded as a matter of course. View "SNAP! MOBILE v. VERTICAL RAISE" on Justia Law

A dispute arose regarding the statements to be included on the November 3, 2026, Idaho general election ballot describing the effect of a “yes” or “no” vote on Proposition One, the Reproductive Freedom and Privacy Act. After qualifying for the ballot, Idahoans United for Women and Families objected to the ballot statements jointly prepared by the Secretary of State and the Attorney General, arguing they mischaracterized both the initiative and existing law, and failed to clearly and concisely convey the effect of each vote as required by Idaho Code section 34-1810(1)(b). The challenged statements had already been distributed for printing and to county clerks, prompting Idahoans United to seek expedited judicial relief.Previously, in Idahoans United for Women & Families v. Labrador (Idahoans United I), the Idaho Supreme Court reviewed related ballot materials for the same initiative, directing revisions to the short ballot title and fiscal impact statement, and later approving the revised materials. After the initiative qualified for the ballot, Idahoans United objected to the Yes/No Effect Statements, but Respondents declined to revise them. Unable to resolve the dispute, Idahoans United filed an original action in the Idaho Supreme Court seeking writs of mandamus, prohibition, and certiorari.The Supreme Court of Idaho reviewed the case and granted writs of prohibition and mandamus, holding that the Yes/No Effect Statements failed to substantially comply with section 34-1810(1)(b) because they did not accurately and concisely convey the effect of a “yes” or “no” vote. The court prohibited use of the challenged statements and directed Respondents to prepare revised statements. Upon review, the court found the revised statements substantially complied with statutory requirements and allowed them to appear on the ballot. The request for a writ of certiorari was denied as duplicative, and no party was awarded costs or attorney fees. View "Idahoans United v. McGrane/Labrador" on Justia Law